Hornbeck Offshore Services, L.L.C. v. Salazar et al

Filing 272

EXPARTE/CONSENT MOTION to Seal by Michael Bromwich, Bureau of Ocean Energy Management, Regulation, and Enforcement, Kenneth Lee Salazar, United States Department of the Interior. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order)(Piropato, Marissa) (Additional attachment(s) added on 6/15/2011: # 3 Notice of Manual Attachment Proposed Pleading) (caa, ).

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF LOUISIANA

HORNBECK OFFSHORE SERVICES,
LLC, et al.
Plaintiffs,
and

CIVIL ACTION No. 10-1663(F)(2)
SECTION F

DIAMOND OFFSHORE COMPANY,
JUDGE FELDMAN
Plaintiff-Intervenors,
MAGISTRATE 2
MAGISTRATE WILKINSON

v.
THE CENTER FOR BIOLOGICAL
DIVERSITY, et al.,
Defendant-Intervenors,
and
KENNETH LEE "KEN" SALAZAR, et al,
Defendants.

DEFENDANTS’ MEMORANDUM IN SUPPORT OF CONSENT MOTION
TO FILE EXHIBITS UNDER SEAL
Defendants, Kenneth Lee Salazar, the United States Department of the Interior, Robert
Abbey, and the Bureau of Ocean Energy Management, Regulation, and Enforcement
(“Defendants”) hereby file this memorandum in support of their motion to file under seal two
exhibits in support of Defendants’ Objections to Magistrates’ Findings and Recommendation on
Quantum of Attorney’s Fees and Defendants’ Opposition to Plaintiffs’ Objections. Defendants
have conferred with Plaintiffs who do not object to the relief sought herein.
Good cause exists for granting the motion. On February 9, 2011, Plaintiffs moved the
Court to file the billings records of Jones Walker and Venable under seal “to protect from public
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disclosure the sensitive, confidential and/or privileged information” in those records. (Dkt.
#229). This Court granted Plaintiffs’ motion to seal documents on February 10, 2011. (Dkt.
#200).
Plaintiffs filed the billings records of Jones Walker and Venable under seal as an
appendix to their Motion to Set the Amount of Attorneys’ Fees and Costs. (Dkt. #233).
Defendants’ supporting exhibits contain excerpts of those billing records. Given that Plaintiffs
filed these records under seal, Defendants respectfully request to file their supporting exhibits
under seal to protect information that Plaintiffs have identified as “sensitive, confidential and/or
privileged.” (Dkt. #229).
Accordingly, because Defendants’ supporting exhibits contain excerpts of information
that Plaintiffs filed under seal, Defendants respectfully request that the Court authorize them to
file their Opposition and supporting exhibits under seal.

Respectfully submitted this 15th day of June, 2011.
IGNACIA S. MORENO
Assistant Attorney General
U.S. Dept. of Justice, Env’t & Nat. Resources Div.
/s/ Marissa Piropato
GUILLERMO A. MONTERO (T.A.)
BRIAN COLLINS
KRISTOFOR SWANSON
MARISSA PIROPATO
Natural Resources Section
PO Box 663
Washington, DC 20016
Tel: [phone]
PETER MANSFIELD
Assistant United States Attorney
Eastern District of Louisiana
Hale Boggs Federal Building
2

500 Poydras Street, Suite B-210
New Orleans, Louisiana 70130
Tel: [phone]

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